As the Customer Due Diligence (CDD) rule implementation date gets closer, we have seen an increase in questions regarding the types of events that may lead a credit union to review the beneficial ownership information of an existing account. So we thought it would be helpful to go over the rule requirements and give examples of potential triggering events. Before we dig in, remember that the definition of a beneficial owner includes two prongs ownership and control so when talking about updating information on beneficial owners, we are referring to both prongs..
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